Supreme Court Cases

 

Helix Energy Solutions Group, Inc. v. Hewitt

Docket: 21-984 Decision Date: 2023-02-22
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This links to the official slip opinion PDF.

Summary

A short, plain-English overview of Helix Energy Solutions Group, Inc. v. Hewitt.

In Helix Energy Solutions Group, Inc. v. Hewitt, the Supreme Court addressed whether Michael Hewitt, a highly paid employee on a daily-rate basis, was exempt from overtime pay under the Fair Labor Standards Act (FLSA). The Court examined whether Hewitt was paid on a salary basis as defined by the applicable regulations. The Fifth Circuit had concluded that Hewitt was not paid on a salary basis, thus entitling him to FLSA protections.

Holding

The single most important “bottom line” of what the Court decided in Helix Energy Solutions Group, Inc. v. Hewitt.

The Court held that Hewitt was not an executive exempt from the FLSA's overtime pay guarantee because his daily-rate compensation did not meet the salary basis conditions set out in § 541.604(b).

Key Quotes

Short excerpts from the syllabus in Helix Energy Solutions Group, Inc. v. Hewitt that support the summary and concepts above.

  • "An employee will be considered to be paid on a 'salary basis' . . . if the employee regularly receives each pay period on a weekly, or less frequent basis, a predetermined amount."
  • "Helix did not pay Hewitt on a salary basis as defined in § 602(a), a conclusion that follows from the text and the structure of the regulations."
  • "The broader regulatory structure—in particular, the role of § 604(b)—confirms the Court's reading of § 602(a)."

 

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